Fourth Amended Complaint

Fourth Amended Complaint

DEFENDANTS' MOTION TO STRIKE PLAINTIFFS' FOURTH AMENDED COMPLAINT PURSUANT TO SECTION 2–603, OR IN THE ALTERNATIVE, DISMISS COUNTS IV, V, VI VII, AND VIII PURSUANT TO SECTION 2–619.1 OF THE CODE OF CIVIL PROCEDURE
Defendants, Gerry Goldman and Mary Goldman, by their attorneys, ADLER, MURPHY, & MCQUILLEN LLP, and respectfully moves this Court to dismiss their the Fourth Amended Complaint with prejudice pursuant to section 2–603 of the Code of Civil Procedure, or in the alternative, dismiss Counts, IV, V, VI, VII and VIII of Plaintiffs' Fourth Amended Complaint pursuant to section 2–619.1 of the Code of Civil Procedure (735 ILCS 5/2–619.1 (West 2014)). INTRODUCTION This case involves a simple landlord–tenant dispute between Plaintiffs, Debra ... Show more content on Helpwriting.net ...(4th Amend. Compl. ¶¶ 45.) According to her allegations, Nenn "definitively learned" that her medical issues were connected to the mold exposure at the property. (4th Amend. Compl. ¶ 53.) Thereafter, Nenn allegedly hired mold testing experts to inspect the property, who allegedly "confirmed" the dangerously high mold levels. (4th Amend. Compl. ¶¶ 49–50.) Plaintiffs also allege that the Village of Algonquin inspected the property and, "upon information and belief," confirmed that the property was in disrepair and had dangerously high mold levels; however, Plaintiffs have not attached any documentation to support that allegation. (4th Amend. Compl. ¶¶ 69–70.) Plaintiffs allege that they were unable to return to the property after their diagnoses and the September 2014 inspection. (4th Amend. Compl. ¶ 74.) Plaintiffs vacated the premises on October 3, 2014, 41 days after first notifying Defendants of the alleged toxic mold. (4th Amend. Compl. ¶

... Get more on HelpWriting.net ...